Delegation of the European Union to the Holy See, to the Order of Malta and to the UN Organisations in Rome ...

11.02.2013

The report concludes on the "central role of biofuels in provoking high and volatile food prices". There is no consensus on the ranking of factors contributing to price hikes and volatility. The European Commission services would like to invite to update and complement the literature review on the impact of biofuels on price levels and volatility. While economic models have their limits, they nevertheless provide some assessment. This should indeed be completed by studies that are more suited to capture more disaggregated (e.g. local) effects.

While products like oilseeds are used for biofuels, co-products are used for feed purposes. Developments in the global feed markets are missing (with the exception of a dedicated chapter on soybeans imports into China). The global share of crops used for feed is almost 20 times larger than the share of crops used for energy purposes. The feed dimension is also missing in the reference to the report of the Joint Research Centre quoted on P. 10.

Currently around 2% of the global arable land is used for biofuel production, and the global share of biofuels used in transport sector is far from 10%. Alternative transport fuels do not only include first generation biofuels produced from crops that require agricultural land. The diversity of different alternative transport fuels including gas, biogas, hydrogen and electricity use in transport sector is increasing, as well as the use of advanced biofuels that are produced from residues, waste and lignocelullosic material, as it is stated later in the text. In the EU – infrastructure for refuelling the vehicles and vessels already exists for all these types of fuels, and the Commission has just proposed measures under the Clean Power for Transport package to ensure the build-up of alternative fuel stations across Europe with common standards for their design and use.

Biofuels are used, particularly in many developing countries in remote areas for many purposes, including cooking (to replace charcoal) and access to energy (incl. lightning). It is not limited to transport sector only, as it is rightly stated later in the text.

The EC participates the work of GBEP, BEFSI, and FAO on development of tools how to improve the knowledge about the impacts of bioenergy on food security and how to develop integrated energy – food systems.

Comments on the text:

1. We would like to invite the experts to make necessary amendments in the 4th and the 5th sentence on page 1o of recommendations and on pages 7 and 14 as well as in Appendix, page 61 as regards the EU policy, since the 0 version does not correctly reflect the EU policy on biofuels.

In 2003, the Directive on promotion of biofuels and other renewable energy sources in the transport sector was adopted (2003/30/EC). I.a., it introduced an indicative target of 5,75% of the share of the renewable energy sources in the transport sector, not limited to biofuels only. However, the Member States were not obliged to reach this target. This Directive was repealed by the Renewable Energy Directive of 2009.

The EU Renewable Energy Directive of 2009 sets a target for the 10% share of all renewable energy sources in the transport sector by 2020, that includes all renewable energy sources, not only biofuels. The choice of the renewable energy sources and support instruments is a competence of EU Member States. Mandatory or indicative biofuel incorporation targets and blending mandates are low for most of the Member States and other support instruments differ from one Member State to the other. At the EU level legal incentives and financial support is provided for development and deployment of advanced biofuel technology.

Based on the Renewable Energy Directive (Article 19.6), in October 2012, the European Commission tabled a legislative proposal to limit the contribution of conventional biofuels towards the renewable energy target to 5% and to increase the support for advanced biofuels that are produced from feedstock that do not use land, including algae, straw, and various types of waste. The Commission's proposal was submitted for co-decision to the EU Member States and to the European Parliament.

Summary of the legislative proposal of 17 October 2012:

Adopted on 17 October 2012: Impact assessment and legislative proposal on indirect land use change related to biofuels as required by the EU Renewable Energy and the EU Fuel Quality Directive:

While existing investments should be protected, the current proposal:

limits the contribution that conventional biofuels (with a risk of ILUC emissions) make towards attainment of the targets in the Renewable Energy Directive to current consumption levels (5%);

improves the greenhouse gas performance of biofuel production processes (reducing associated emissions) by raising the greenhouse gas saving threshold for new installations;

encourages a greater market penetration of advanced (low-ILUC) biofuels by allowing such fuels to contribute more to the targets in the Renewable Energy Directive than conventional biofuels; and

improves the accounting of greenhouse gas emissions by obliging Member States and fuel suppliers to report the estimated indirect land-use change emissions of biofuels.

All documents, including the legislative proposal, FAQ and Impact Assessment can be found on the DG Energy homepage:

The decision process on that proposal is on-going within the EU, especially in the Council and the European Parliament.

Therefore, related references to the EU would need to be specified, especially on p.14, under Land use change, the following specifications could be added:

In October 2012, the European Commission proposed to modify the mandated EU targets and to cap biofuels based on food crops at 5%. The EU decision process on that legislative proposal is on-going.

2. Sentence 3 on page 5 as well as the draft recommendation No 4 on page 6 regarding the impact of biofuels to the position of women do mention only challenges that are related to the land use rights and access to forest products. For example, evidence from Mozambique shows also positive experiences with bioethanol as a replacement product for charcoal which improves firstly the quality of life of women as it saves the time needed for cooking while improving health conditions while saving the wood and energy needed for production of charcoal. (Clean Star Initiative: http://www.cleanstarmozambique.com).

3. Sentence 6 on page 5, recommendations 6 and 7 and information on page 51 do not correctly reflect the EU biofuel sustainability scheme which includes mandatory sustainability criteria, i.a., related to the land use, greenhouse gas emission savings compared to fossil fuels and biodiversity.

Other environmental and social issues as sustainability related to water, air and soil quality as well as food security, are addressed already under current legislation through monitoring and reporting requirements as well as through most of the voluntary biofuel certification.

Experience with these schemes since 2011 shows no indication that they could become innocuous, as the voluntary schemes with multi-stakeholder participation are the most popular in the exporter countries to the EU. The Commission's report, i.a., on impacts of the EU production and use of biofuels on the environment and social aspects will be published shortly.

The EU and many EU – Member States are Members of GBEP and participate in the work of GBEB on bioenergy sustainability. In 2012 GBEB adopted 24 sustainability indicators, which are currently being tested in both, developed and developing countries.

Statistics show that most of EU biofuel consumption stems from EU sources, with only about 20% of biofuels being imported. Most of the EU produced biodiesel feedstock in 2010 was produced from EU grown rapeseed (56%), followed by soybean (13%) and palm oil (9%). More than half of the EU produced ethanol is made of EU produced feedstock (30% wheat, 30% sugar beet, smaller contributions from barley and rye), followed by imported sugarcane and maize.

In 2008, the total gross land use associated with EU biofuel consumption in 2008 was estimated to be 7 Mha, of which 3.6 Mha in the EU and 3.3Mha in third countries (estimated that 590 kha is required per Mtoe of biofuels). If accounting for co-products that reduce land needs elsewhere, the total net land use for EU biofuels is estimated at 3.6 Mha.[1]

4. As regards the draft recommendation 8 recent Commission studies show the importance of proper agronomic analysis and training as well as strategic environmental impact assessments (Reference to the study will be provided once it is published).

5. As regards information on the discussion around the Land Grabbing issue,described on page 42, we would like to invite the experts to further refer to on-going work within the CFS on the Voluntary Guidelines on the Responsible Governance of Tenure of Land, Fisheries and Forests in the Context of National Food Security and to the on-going consultation on Responsible Agricultural Investments.

An increasing body of new studies have emerged covering the phenomenon of large scale land acquisition; all point towards one commonly recognised problem: a lack of transparency and availability or reliable data. Recent wide ranging studies undertaken by the World Bank[2] and most recently by the Land Matrix Project[3], note the remarkable difficulties in obtaining reliable data from target country registries as well as from investors. Data on large scale land acquisition is most difficult to obtain on the actual implantation status of the announced contracts in terms of production being carried out, previous land users and land use, the displacement of food production and land evictions. It is also difficult to precisely determine the final use of crops grown as part of deals in large scale land acquisition, the growth of investors’ interests in “flex crops” and crops destined for “multiple uses” i.e. either biofuels or food (sugarcane, soy, palm oil) in terms of area covered in hectares points out that the potential of using crops for biofuel production is an important consideration in investment strategies.

6. P.14

The sentence "In addition Europe´s cooperation for development programs would no longer support biofuels investment projects" should be replaced by "The Commission is currently carrying out evaluation of the impacts of the EU-funded biofuel projects on development in ACP countries".

The Commission indeed launched a study to assess the impact of biofuels production on developing countries from the point of view of Policy Coherence for Development. While the study is not fully finalised, the Commission has decided to move forward with utmost prudence.

[3] The Land Matrix Partnership is made of ILC, CIRAD, The GIGA German Institute of Global and Area Studies and GIZ (The Deutsche Gesellschaft fur Internationale Zusammenarbeit). The database has been made publically available at http://landportal.info/landmatrix